George N. and Maggie Ahmaogak - Page 7

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               Our 1989 return was audited, brought to the Appeals                    
               Office, and in Tax Court.  We have a good faith belief                 
               that delays occurred in preforming [sic] ministerial                   
               acts by an officer or employee of the Internal Revenue                 
               Service during that period.  The occurance [sic] of                    
               such delays requires the abatement of the assessment of                
               interest for those particular periods.  Furthermore,                   
               throughout much of this period legislation was pending                 
               which would have substantially affected the treatment                  
               of specific deductions.  Accordingly, the Service                      
               postponed consideration of these matters.  Further, a                  
               death in the family of our legal counsel resulted in an                
               additional delay in consideration of our case.  In                     
               light of the ministerial delays, and as well as our                    
               reliance on the actions of Congress, the failure to                    
               abate interest in our circumstances would constitute                   
               grossly unfiar [sic] treatment and impose on us an                     
               undue hardship.                                                        
                                                                                     
          Elsewhere on the abatement claim, petitioners indicate that the             
          amount to be “refunded or abated” is “approximately [$]2,400”.              
          In the area designated “Period--prepare a separate Form 843 for             
          each tax period”, petitioners entered “from March 8, 1993 to                
          October, 1999.”  Try as we have, we are unable to appreciate the            
          relevance of this period to the relief requested by petitioners             
          either in the abatement claim or in this proceeding.  Block 4a of           
          the abatement claim provides for a check-the-box entry if the               
          request is for abatement or refund of “interest caused by IRS               
          errors or delays”.  This box is left blank, as is the following             
          area where the “dates of payment” should have been inserted.                
               Despite its many infirmities, respondent considered the                
          abatement claim as a request for abatement of all interest that             
          had accrued with respect to petitioners’ 1989 Federal income tax            
          liability.  As earlier noted, with the exception of $8.61, all of           



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